Description of Advisory Firm ALPS Advisors, Inc. (“AAI”) was founded in 2006. AAI is a subsidiary of ALPS Holdings, Inc., (“AHI”) which is a subsidiary of DST Systems, Inc. (“DST”), which in turn is a wholly owned subsidiary of SS&C Technologies, Inc. SS&C Technologies, Inc. is a wholly owned subsidiary of SS&C Technologies Holdings, Inc. (Nasdaq: SSNC)(“SS&C”). Description of Types of Advisory Services Registered Investment Companies AAI currently serves as an investment adviser to investment companies (each a “fund” and collectively, the “funds”) registered under the Investment Company Act of 1940 (“1940 Act”). AAI has the responsibility to appoint on behalf of the funds it advises, sub-advisers with full investment discretion, which may include the selection of brokers and other trading counterparties. AAI has the responsibility to oversee the activities of the sub-advisers and ensure that all transactions comply with applicable regulations and prospectus covenants. AAI also has the ability to serve as investment sub-adviser to investment companies registered under the 1940 Act. In addition, where AAI is the adviser or sub-adviser, there are certain funds for which AAI will initiate placement, execution, and settlement of trades. In these instances AAI will not actively make specific security investment decisions. Rather AAI’s trading desk will be responsible for initiating trades necessary to keep the funds in line with a model portfolio provided by the adviser, sub-adviser or, in the case of an exchange traded fund, the indexing agent or at the direction of the adviser or sub- adviser. Sub-Advisory Services AAI will enter into sub-advisory agreements with other registered investment advisers to provide certain investment management services those advisers. The sub-advisory services offered by AAI include but are not limited to: conducting trades in custodial accounts as directed by the primary adviser; providing access to model portfolios managed by third party investment managers; and providing a platform to assist the primary adviser with implementing model portfolios managed by the primary adviser. Other registered investment advisers who enter into a sub- advisory agreement with AAI will delegate their discretionary authority to conduct trades on behalf of specified accounts held at a custodian. AAI will use this discretionary authority to implement model portfolio selections or direct trade instructions provided by the primary investment adviser. When AAI acts as a sub-adviser, the primary adviser is responsible for ensuring that it complies with all applicable statutes, regulations, and rules. Furthermore, the primary adviser is responsible for assessing whether instructions, provided to AAI, regarding the selection of a model portfolio, the purchase of a security, or the sale of a security meet the applicable suitability/best interest standards. Retirement Solutions Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. AAI may provide retirement plan services to plans and plan fiduciaries, as described below. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which plan fiduciaries may retain investment

advisers for various types of services with respect to plan assets. For certain services, we will be considered a fiduciary under ERISA. For example, we will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the plan fiduciaries by recommending a suite of investments as choices among which plan participants may select. With respect to any account for which we meet the definition of a fiduciary under Department of Labor rules, we acknowledge that both the firm and its related persons are acting as fiduciaries. Services will be provided under the terms and conditions of a licensing agreement, whereby AAI provides investment analysis, investment performance data and mathematical modeling techniques for use in investment advice software made available to authorized plan participants. Through the software, AAI may provide investment recommendations, among a suite of investments, to authorized plan participants. These investment recommendations will constitute investment advice under ERISA § 3(21). Prior to accepting investment advice, authorized plan participants have the option of entering into an advisory agreement with AAI, which outlines the risks and limitations of accepting such advice. Additional disclosure is found elsewhere in this Brochure or in the written agreement between us and the client. Model Portfolio Solutions AAI constructs and provides model portfolios to other registered investment advisers through SS&C Rendezvous. Among other things, SS&C Rendezvous provides investment advisers the ability to assess their client’s portfolios, implement model allocations, and monitor investments across their accounts. SS&C Rendezvous is solely available to investment advisers through SS&C Advent, an affiliate of AAI, and its Black Diamond Wealth Platform (the “Platform). Investment advisers have the ultimate decision making and discretionary responsibility for the determination of which securities are to be purchased and sold for their account and effect all security transactions in connection with such determinations. In addition, AAI has no specific knowledge of the investment adviser’s clients or their circumstances. ALPS Advisors, Inc. 5 Model portfolios will include third-party ETFs and ETFs that are advised by AAI (“Affiliated ETFs”). As a result, the AAI’s conflict in selecting Affiliated ETFs within a particular model is heightened because it has an additional incentive to decrease the model portfolio's allocation to third-party ETFs in order to increase the investment advisory fees it receives. Refer to Item 5 “Fees and Compensation” below for additional conflicts of interest disclosures. Investment adviser representatives of AAI may provide consultative support and investment advice to investment advisers regarding model implementation and selection. Red Rocks Global Listed Private Equity Index AAI has developed and maintains the Red Rocks Global Listed Private Equity Index (the “Index”). The Index is the basis for an exchange-traded fund which is managed by an unrelated party (the “ETF Provider”). Assets Under Management As of February 29, 2024, AAI had the following client assets under management: Discretionary Assets $24,019,792,910 Non-Discretionary Assets $0 Total Assets Under Management $24,019,792,910